Codeof

Conduct
andBusiness
Ethics
 Table of Contents

MESSAGE FROM THE PRESIDENT and CEO ...........................................................1

1. Introduction ..............................................................................................................2
1.1 About CCC’s Code of Conduct and Business Ethics ...............................................2
1.2 Guiding everything we do at CCC ............................................................................2
1.3 Our Commitment to Values and Ethical Conduct .....................................................3
1.4 Our Core Values and Business Principles................................................................3
2. Our Responsibilities ................................................................................................5
2.1 As an Individual ........................................................................................................5
2.2 Our Integrity Check ..................................................................................................6
2.3 Responsibilities as a Manager .................................................................................8
3. Our Behaviours, People, and Culture .....................................................................9
3.1 Health and Safety.....................................................................................................9
3.2 Diversity and Inclusion ........................................................................................... 10
3.3 Discrimination and Harassment ............................................................................. 10
3.4 Sustainability .......................................................................................................... 11
3.5 Fiscal Integrity and Responsibility .......................................................................... 11
3.6 Human Rights in the Workplace ............................................................................. 11
3.7 Workplace Environmental Impact ........................................................................... 12
4. Managing Risk in Information Management and Communication ..................... 13
4.1 Confidentiality and Disclosure of Information ......................................................... 13
4.2 Transparency ......................................................................................................... 14
4.3 Political Activity ...................................................................................................... 15
5. Managing Risk in International Contracting ........................................................ 16
5.1 Human Rights in International Transactions........................................................... 16
5.2 Anti-bribery and Corruption .................................................................................... 17
5.3 Gifts and Hospitality ............................................................................................... 18
5.4 Conflicts of Interest ................................................................................................ 18
5.5 Environmental Impacts ........................................................................................... 19
6. Conclusion.............................................................................................................. 20
Annex A ...................................................................................................................... 20
Annex B ...................................................................................................................... 20
 MESSAGE FROM THE
PRESIDENT AND CEO

I am pleased to announce and share with you the Canadian Commercial Corporation’s (CCC’s) revised
Code of Conduct and Business Ethics (Code). This Code is a keystone for our vision for responsible
business conduct at CCC.

Our Code will help employees uphold both CCC’s and Canada’s public sector core values when making
decisions. It also supports a positive and respectful work environment and gives our clients confidence in
our conduct. Our Board of Directors is highly supportive of the revised Code and CCC’s enhanced focus
and direction on the areas covered by the Code.

CCC’s success, and our ability to help Canadian exporters by facilitating trade, depends on all employees.
Each of us must adhere to this Code and assume our respective roles with confidence and clarity.
Understanding the Code will help us all do that. I therefore ask that all employees read this Code
thoughtfully and reflect on its importance.

“CCC is committed to conducting its business

responsibly with honesty, integrity and fairness, and
will advance its ethics and values through its expertise
in international contracting”

Our continued dedication to the values embodied in this Code enhances our reputation for integrity
and ethical business practices. It also enables us to be a leader in responsible business conduct, while
serving the needs of Canadian exporters.

Martin Zablocki
President and CEO

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 1
 1. INTRODUCTION

core values as well as Canada’s public sector

1.1 About CCC’s Code values, to which this Code is fully aligned. CCC
of Conduct and Business aims to continually update its suite of procedures
Ethics and policies to align with best in class practices in
the area of responsible business conduct and
This Code of Conduct and Business Ethics corporate social responsibility.
(Code) is a keystone for CCC’s enhanced
approach to responsible business conduct. It 1.2 Guiding Everything
supports a positive and respectful work
environment and ensures our clients can have
We Do At CCC
confidence in CCC’s conduct.
This Code applies to everything that we do here
at CCC and guides our daily behaviours and
Our approach to responsible business conduct
decision-making. It applies to every director,
means that we have in place policies and
officer, employee, contractor, consultant, student
processes that guide our work, particularly with
or other persons working for or representing
regard to human rights, bribery and corruption,
CCC.
the environment, conflict of interest and
confidentiality of information. With these tools to
guide behaviour and decision-making, CCC’s
employees are better equipped to uphold CCC’s

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 2
1.3 Our Commitment to
Values and Ethical Conduct
CCC is committed to ensuring the highest
standards in values and ethical conduct. This
commitment plays a fundamental role in how we
serve Canadian exporters and the public interest
as part of the mandate entrusted to us by the
Government of Canada. As federal public
servants, we all have a role to play in upholding
the public’s trust and contributing to public
confidence in the integrity of CCC.
Regardless of our level or position, we are
also expected to conduct ourselves in all activities
related to our professional duties in accordance
with the Treasury Board’s Values and Ethics
Code for the Public Sector (TBS Code),
(See Annex “A”). These values include:
 Respect for democracy
 Respect for people
 Integrity
 Stewardship
 Excellence
To ensure all CCC employees are aware of, and
adhere to the above requirements. Each CCC
employee must sign, on an annual basis, the
Employee Code of Conduct and Business Ethics
Acknowledgement and Acceptance Form (see
Annex “B”) confirming that the employee has read
and understood both the CCC Code and the TBS
Code. Acceptance of these values and
adherence to the expected behaviours is a
condition of employment for every employee in
the federal public sector. The Employee Code of
Conduct and Business Ethics Acknowledgement
and Acceptance Form is kept in the employee’s
Human Resources file.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
Members of CCC’s Board of Directors must also
adhere to the Ethical and Political Activity
Guidelines for Public Office Holders as a
condition of holding office in the Government
of Canada.
1.4 Our Core Values and
Business Principles
CCC is committed to excellence in serving
Canadian exporters. As such, CCC abides by the
following core values and business competencies
in guiding its business activity.
Integrity: Trust, fairness and honesty are intrinsic
to all our interactions and we expect the same
from our clients and our customers. Employees
should always act in good faith and in the best
interests of CCC.
Professionalism: Dedication and skill is our
strength at CCC. We approach our work with the
highest levels of professionalism, and demand
the same from the Canadian companies we help
and the foreign governments who buy their
products and services. Employees should adopt
high standards of behaviour and demonstrate
competence at all times. We should portray a
respectable and positive image to colleagues,
clients, customers and members of the public,
when representing CCC in Canada or
internationally.
Responsibility: We are committed to upholding
our responsibilities and accountabilities as a
Crown corporation and a corporate citizen. We
believe in sustainable business practices and
maintaining transparent relationships with all of
our stakeholders. In our business transactions,
we seek to operate with integrity and with respect,
recognizing our responsibilities in the areas of
human rights, anti-corruption and
the environment.
3
CCC’s core values and competencies underpin
all of our work and enable us to deliver on our
Employees are the
corporate objectives and Canadian exporter custodians of CCC’s
needs. CCC’s core competencies are as follows:
reputation, and by
Business Perspective: At CCC, we strive to
have a clear understanding of business issues,
extension, the
processes and outcomes to ensure we deliver Government of Canada’s.
value for Canadian exporters.
We behave with integrity
Client-focus: At CCC, we are client-focussed,
endeavouring to find solutions for Canadian
to uphold Canada’s
exporters navigate complex markets. We also strong image abroad.
focus on service excellence as a means of
enhancing business performance. Our team
strives to be creative and adaptable in finding
solutions to clients’ needs. We have a responsibility
Teamwork: At CCC, we recognize that the team to act, in all
is stronger than the individual, and that people circumstances, in a
are our strength. We work collaboratively with
others to achieve our goals and those of our manner that respects
clients. We build lasting relationships through
respect for others and ourselves. We value and
and protects CCC and
respect diverse cultures, customs and business the Government of
practices in Canada and internationally.
Canada’s reputation.
Compliance with these values is also
fundamental to ensuring CCC’s reputation as
a trusted partner in international trade.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 4
 2. OUR RESPONSIBILITIES
2.1 As an Individual
CCC has developed this Code to promote the
ethical and professional behaviour of employees
and to assist employees and representatives in
daily decision-making.
Your Responsibilities
 Read, understand and follow this Code.
 Understand the risks in your particular role
and how to manage them.
 Seek advice when things are not clear
or you are unsure of how to deal with
a situation.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
 Ensure third-party contractors, agents or
consultants are aware of, and abide by, our
Code when representing CCC.
 Report any breaches of this Code to CCC’s
Human Resources or Legal Team.
Whistleblowing and Wrongdoing in
the Workplace?
It is important to understand that the Public
Servants Disclosure Protection Act (PSDPA)
offers CCC’s employees, and other persons who
disclose information concerning wrongdoing, the
right to be treated fairly and be protected from
reprisal. In addition to the Code, CCC also has a
policy regarding the Disclosure of Wrongdoing in
the workplace.
5
Further to this policy, all reports of serious
wrongdoing in the workplace, including serious
breaches of the Code, will be investigated in a
secure and confidential manner, and corrective
and/or disciplinary actions will be taken as
appropriate. These actions will be in accordance
with the Government of Canada’s and CCC’s
policies and regulations, and the collective
agreement between CCC and the Professional
Institute of the Public Service of Canada, when
applicable.
Integrity is the cornerstone of good governance
and democracy. CCC employees serve the public
interest by:
 Acting at all times with integrity and in a
manner that withstands public scrutiny and
maintains the public’s trust.
 Never using our positions to obtain an
inappropriate advantage.
 Taking all possible steps to prevent and
resolve any real, apparent or potential
conflicts of interest.

FURTHER To help clarify a dilemma relating to this

READING Code, work through the questions in the
Integrity Check:
CCC’s Policy on Disclosure of Wrongdoing.
When in doubt, ask yourself…

2.2 Our Integrity Check Am I upholding CCC’s core values of

professionalism, integrity and responsibility? Is it
ethical? Is it legal? Have I thoroughly understood
the potential risks, including the potential impact
Integrity is non- of a decision on CCC’s or the Government of
negotiable at CCC. We Canada’s reputation? Would we be embarrassed
if others knew CCC or one of its employees took
expect the same from the this action?
Canadian exporters and
foreign governments
with whom we work.

Trust, fairness and

honesty are intrinsic to
all our interactions.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 6
CCC’s policies and procedures are designed to
help you think about these important questions
and guide you through the decision-making
process. We all have a responsibility to ensure
we always do what is right.
Ask yourself each of these important questions,
and see if you get a “green light” to move on to
the next question, or whether you need to
“proceed with caution.” You may need to seek
advice, or even stop. Then move on to the next
question until, ultimately, you are certain it is
appropriate for you to proceed.

Is it ethical?

Unsure? Seek Advice Report Immediately

Is it legal?

Unsure? Seek Advice Report Immediately

Have I thoroughly understood the potential risks, including the potential to reflect negatively on CCC?

Unsure? Seek Advice Report Immediately

Would we be embarrassed if others knew CCC or one of its employees took this action?

Unsure? Seek Advice Report Immediately

PROCEED

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 7
2.3 Responsibilities as
a Manager
Every CCC manager is expected to demonstrate
leadership in respecting and promoting the
standards of this Code, and is responsible for
explaining and clarifying any questions, concerns
or matters of interpretation relating to this Code
to team members.
Manager’s responsibilities:
 Read, understand and follow this Code.
 Understand the risks that apply in your
business or function in terms of the
application of this Code, and the procedures
required to mitigate risks.
 Ensure members of your team understand
the procedures to be followed. This includes
the requirement to declare potential conflicts
of interest, and gifts and hospitality.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
 Ensure new employees or team members
are briefed on this Code, the risks presented
by their role, and sources of advice
and support.
 Be alert to any violations of this Code, and
encourage your team members to speak up
if they know or suspect a violation.
 If you are informed of a possible violation of
this Code, you have a duty to report it to
your supervisor, your Human Resources
representative, CCC Legal Counsel or the
CCC Senior Officer for Disclosure of
Wrongdoing (Vice President, Legal
Services, General Counsel and Corporate
Secretary).
 Implement appropriate actions in response
to a violation of this Code.
8
 3. OUR BEHAVIOURS, PEOPLE, AND
CULTURE

We want CCC to be a great place to work and we

want to protect our reputation as an organization
that always strives to do the right thing.
To do that, we must conduct all CCC business in
a manner that lives up to our core values of
integrity, professionalism and responsibility.
3.1 Health and Safety
We are committed to ensuring that the
Corporation’s work environment is both healthy
and safe. No employee should undertake an
action or activity that would jeopardize his/her
own health and safety, or that of others.

This section of the Code sets out the standard

of behaviour expected at CCC.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 9
CCC aims to promote high standards of
employee health and wellness. Consistent with
the spirit and intent of this commitment, CCC has
established a comprehensive policy regarding
the use of drugs and alcohol to minimize the risks
associated with intoxication or impairment in the
workplace. The use of alcohol, cannabis, and
other drugs can affect workplaces in a number of
ways including increasing the risk of workplace
injury, absenteeism, diminished quality of work,
strain on work relationships, and deterioration in
employees’ physical, emotional, and mental
health. Accordingly and as further detailed in this
policy, CCC employees are prohibited from
impairment when conducting CCC business
activities, either at work or offsite.
Employees will make every effort to:
 Ensure we are fit for work every day.
 Take all reasonable precautions to ensure
job safety and continuously strive to
improve safety.
 Work to promote safety awareness and a
safety-first mindset.
 Emphasize prevention, the removal of
unsafe conditions and the elimination of
unsafe behavior.
 Follow safe work practices and procedures.
 Not compromise health and safety for
any reason.
FURTHER
READING
CCC’s Health and Safety Policy, Joint Health
and Safety Committee Policy, and Alcohol
and Drug Policy.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
3.2 Diversity and Inclusion
People are at the core of CCC’s success and at
the heart of our business. CCC’s competitive
advantage and reputation are enhanced when
our workforce and decision-making reflects the
principles of diversity and inclusion.
To support this commitment to a diverse and
inclusive work environment, we must:
 Promote diversity and inclusion within
our teams.
 Seek, respect, value and leverage diversity
of thought and ideas.
 Hold ourselves accountable to share in the
responsibility for inclusiveness.
 Ensure that inclusiveness is visible in
decision-making and behaviour.
 Abide by the principle that all of our
relationships are based on mutual respect
and growth.
3.3 Discrimination and
Harassment
Employees have the right to receive fair and
equitable treatment, and are entitled to a
harassment-free workplace. Each of us has a
responsibility to ensure that CCC provides a safe,
respectful and inclusive environment, free of
discrimination and harassment.
To ensure we can achieve this, we must:
 Treat others with respect at all times.
 Avoid physical or verbal intimidation.
 Ensure humiliating, hostile or intimidating
treatment towards others is not tolerated
at CCC.
 Promote a work environment free from
discrimination and harassment.
10
 FURTHER
READING
CCC’s Anti-Harassment Policy, Workplace
Violence Prevention Policy and Recognizing
Workplace Harassment Guidelines.
3.4 Sustainability
CCC’s goal is to ensure that sustainability is a
core component of its business strategy.
Employees can contribute to sustainability by
promoting open dialogue with stakeholders on
CCC’s economic, social and environmental
objectives, including CCC’s commitment to
upholding Canada’s respect for international
human rights.
Promoting a sustainable approach to business
can ensure we are each doing our part to ensure
a long-term, globally minded and holistic
business perspective and serve to protect the
future of CCC and Canadian industry.
FURTHER
READING
CCC’s Responsible Business Conduct
Framework.
CCC seeks to work with
Canadian exporters who
are committed to
responsible business
practices.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
3.5 Fiscal Integrity and
Responsibility
As federal public servants, we must be fiscally
responsible in all business activities and ensure
value for money is recognized. We are expected
to exercise responsible management of
expenditures and use corporate facilities and
assets with prudence.
All corporate assets should be used only for
lawful and proper purposes, and should be
protected from theft, misuse or damage.
3.6 Human Rights in
the Workplace
CCC is committed to creating and maintaining a
work environment that is free from harassment
and discrimination on prohibited grounds,
including: race, national or ethnic origin, colour,
religion, age, sexual orientation, gender, gender
identity or expression, marital status, family
status, genetic characteristics or disability.
We recognize cultural differences and in CCC’s
business activity support internationally agreed
conventions on human rights and labour rights,
including the United Nation’s Universal
Declaration of Human Rights and the
International Labour Organization’s Declaration
of Fundamental Principles and Rights at Work.
CCC upholds human rights in the workplace
through:
 Health and safety at work.
 Equitable working conditions.
 The right to equal pay and benefits.
 Freedom of association and the right to
collective bargaining.
CCC is a unionized work environment, and is
guided by a collective agreement that details
11
employee rights with regard to working
environment, leave, travel and other terms and
conditions of employment.
FURTHER
READING
CCC’s Official Languages Policy, Flexible
Work Policy and Collective Agreement.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
3.7 Workplace
Environmental Impact
CCC enhances responsible corporate citizenship
through active stewardship of its operations.
CCC is committed to building a more sustainable
society by striving to minimize our environmental
footprint and developing solutions that conserve
resources and protect our planet. All employees
are encouraged to improve our daily operations
on a continuous basis with the objective of
environmental consciousness.
FURTHER
READING
Greening CCC Operations Policy.
12
 4. MANAGING RISK IN INFORMATION
MANAGEMENT AND COMMUNICATION

At CCC, we respect the 4.1 Confidentiality and

privacy rights of our Disclosure of Information
employees, the CCC creates, uses and protects information in
a responsible way, especially when it comes to
companies we work with personal details, commercially sensitive
information and intellectual property – both our
and our business own and that of others. CCC employees are
partners. We are responsible for following internal policies and
procedures aimed at protecting the confidentiality
committed to managing of third party information held by CCC in
connection with our business activities.
personal data in a
professional, lawful and
ethical way.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 13
All CCC employees are responsible for ensuring
the confidentiality, integrity and availability of the
Corporation’s information assets.
CCC respects the privacy rights of its
stakeholders, including their right to the security
of their personal information, and ensures that the
use of their information, is only for the purposes
for which it was originally provided and collected.
Requests for Information
As a Crown corporation, CCC is subject to the
Access to Information Act and the Privacy Act
governs CCC’s collection, use, storage and
disclosure of information.
 The Access to Information Act gives
Canadian citizens and permanent residents
access to information in federal government
records. When a request has been received
under the Access to Information Act, CCC
employees must ensure that they do not
destroy, alter, falsify or conceal a record
relating to the request, in contravention of the
Act.
 The Privacy Act gives Canadian citizens and
permanent residents the right to access their
personal information held by federal
agencies and protects the information
against unauthorized use or disclosure.
Access to Information and Privacy (ATIP)
requests are managed by CCC’s ATIP Office.
Accordingly, employees should refer requests for
information to the CCC ATIP Office or to the CCC
Legal Team. These teams can also assist you
with managing other requests for information.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
Inquiries from Media, General Public
and Parliamentary
All inquiries should be directed to CCC’s Director
of Communications. Please note that only CCC’s
designated spokesperson(s) is entrusted with
issuing a statement or making public comments
regarding CCC’s position on a given subject.
When asked to comment publicly on issues
related to CCC or its work, employees should
refer the enquiry to CCC’s Director
of Communications.
FURTHER
READING
CCC’s Procedures for Handling
Enquiries/Correspondence Received from
Ministers, Senators or Members
of Parliament, Security Operational Policy
and Information Security Instruction.
4.2 Transparency
Transparency is a core guiding principle of our
enhanced approach to responsible business
conduct. We are committed to working in an open
and transparent manner, while balancing the
need for confidentiality and the protection of
interests entrusted to us by Canadian exporters
and other partners.
14
Our commitment to conducting business
transparently is carried out through the following:
Annual Corporate Reports
 Corporate Plan: CCC’s annual Corporate
Plan sets out its business strategies,
performance measures and targets over a
five-year planning horizon. It is available on
our website.
 Annual Report: CCC’s Annual Report
presents our results against its business
strategies, performance measures and
targets as set forth in the Corporate Plan, and
reports on our compliance with the Canadian
Environmental Assessment Act and the
Financial Administration Act.
Financial Reports
 Quarterly Financial Reports: CCC releases
its financial results against targets set forth in
the Corporate Plan on a quarterly basis.
Stakeholder Engagement
 Annual Public Meeting: CCC conducts an
annual public meeting to provide information
on activities, results and strategic directions,
as well as to answer questions from the
public. This meeting forms part of our plan to
continually enhance transparency and gain
insight on shareholder and stakeholder
considerations.
 Quarterly and Regular Reporting: CCC
reports regularly to Global Affairs Canada
and the Minister of International Trade
Diversification, and other central agencies on
a variety of topics, including international
pursuits and transactions as part of our
human rights consultation process, and
Significant Project Instruction.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
Annual Reporting Requirements
In addition to information included in CCC Annual
Report, CCC also tables the following reports
Pursuant to applicable legislative requirements:
 Access to Information and Privacy Statistical
Reports included as part of the ATIP Annual
Reports tabled by the Minister of International
Trade Diversification in Parliament. CCC also
provides Monthly Travel and Hospitality
Reports regarding senior officers required by
the Access to Information Act.
 Official Languages Act Report to Parliament
through the Official Languages
Commissioner.
 Corruption of Foreign Public Officials Act
(CFPOA) Report tabled in Parliament
through the Minister of Foreign Affairs.
 Employment Equity Act Compliance Reports
to Employment and Social Development
Canada.
 Export and Import Permits Act amendments
to accede to the Arms Trade Treaty will
require transactional reporting by CCC
through the Minister of Foreign Affairs in
a form to be directed by Global
Affairs Canada.
FURTHER
READING
CCC’s Transparency and Accountability
Policy.
4.3 Political Activity
Employees may engage in any political activity so
long as it does not impair, or is not perceived as
impairing, the employee's ability to perform his or
her duties at CCC in a politically
impartial manner.
15
 5. MANAGING RISK IN INTERNATIONAL
CONTRACTING

The Government of 5.1 Human Rights in

Canada believes in the International Transactions
importance of Canada is committed to the protection of human
rights at home and abroad. As a federal Crown
responsible business corporation, and as outlined in our Human Rights
Policy and Human Rights Due Diligence
conduct and the duty of processes, CCC strives to operate in a manner
Canadian companies to consistent with the policies of the Government of
Canada, taking into account the commitments
respect human rights, Canada has made to abide by international
human rights principles.
both in Canada and
abroad. CCC is committed to respecting all internationally
recognized human rights in line with the United
Nations Guiding Principles on Business and
Human Rights and the Organisation for Economic
Co-operation and Development Guideline’s for
Multinational Enterprises.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 16
Adhering to these standards is an important
aspect of our risk management as we strive to:
 Review human rights as part of our project
risk reviews.
 Identify human rights risks and sensitive
transactions.
 Ensure CCC has processes to help prevent,
mitigate and monitor human rights impacts.
 Protect our reputation and the reputation of
the Government of Canada.
 Contribute to our long-term sustainability
through the above.
FURTHER
READING
CCC’s Human Rights Policy and CCC’s
Human Rights Due Diligence processes.
5.2 Anti-bribery and
Corruption
CCC seeks to be a leader in promoting
due diligence in the area of corruption and
anti-bribery.
Our Integrity Compliance Instruction and Fraud
Policy provide guidelines for employees as to
how we manage areas of risk related to integrity,
bribery and corruption and fraud. Ensuring that
CCC’s transactions are of the highest ethical
standard is not achieved simply through strong
up-front due diligence. Proper oversight by CCC
officers during business development and
contract management activities have an equally
important role to play as corruption can take place
at any point throughout a contract.
We take Integrity Compliance seriously at CCC.
We also recognize that new issues and matters
of concern can occur. We encourage all
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
employees to raise any concerns regarding
bribery and corruption to CCC’s Integrity
Compliance Committee.
Outlined below are details regarding how we
address anti-bribery and corruption concerns
for CCC transactions as well as our obligations
under the Corruption of Foreign Public
Officials Act.
CCC Transactions
CCC’s role in international government-to-
government contracting on behalf of the
Government of Canada is unique. As such, we
have a duty to uphold our integrity and that of the
Government of Canada, as well as enforce the
ethical values set out in this Code. To do this,
CCC completes:
 Ethical risk assessments.
 Integrity due diligence.
 Reviews of contractual obligations in CCC’s
international contracts with Canadian
exporters and foreign buyers to include
provisions to address bribery and corruption.
 Periodic training of business development
officers and other individuals in contact with
foreign buyers.
 Contract monitoring for ethical compliance.
 Procedures and reporting to deal with
violations and alleged violations.
 While these safeguards are not absolute,
they serve to significantly mitigate risks.
17
Compliance with Canada’s Corruption of
Foreign Public Officials Act (CFPOA)
CCC also complies with Canada’s Corruption of
Foreign Public Officials Act (CFPOA). The
CFPOA states that it is illegal to bribe a foreign
public official.
A bribe consists of directly or indirectly, giving,
offering or agreeing to offer a reward, advantage
or benefit of any kind as consideration for an act
or omission by the official or to induce the official
to use his position to influence acts or decisions
of the foreign states.
FURTHER
READING
CCC’s Integrity Compliance Instruction and
Fraud Policy.
5.3 Gifts and Hospitality
CCC’s Travel, Hospitality, Conference & Event
Expenditures Policy provides detailed guidelines
for employees regarding gifts and hospitality.
Employees may not accept or solicit gifts,
hospitality or other benefits that have a real or
potential influence on their objectivity in carrying
out their duties or which could, or be perceived,
to influence their decision-making. This includes
cash, personal items or other inappropriate gifts.
If it is impossible to decline a gift, hospitality and
other benefit without causing offence, the
recipient should notify and discuss the situation
with their Vice-President or the President, as set
out in the Travel, Hospitality, Conference & Event
Expenditures Policy.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
We recognize that some situations can be difficult
to navigate. Employees can always refer to
CCC’s policy on this matter or further discuss any
questions with their Vice-President or the
President, for additional clarification.
FURTHER
READING
CCC’s Travel, Hospitality, Conference
& Event Expenditures Policy
5.4 Conflicts of Interest
What is a conflict of interest?
A conflict of interest exists when by serving one
interest, our actions are incompatible with, or
could improperly influence, another interest. In
the employment context, a conflict of interest
arises when an employee must choose between
CCC’s interests and his/her own
personal interest.
Why is this important?
As employees: CCC staff are required to act in
the best interests of CCC.
As a client-facing organization: CCC is called
upon to act in the best interests of the Canadian
exporters we support under our Government of
Canada mandate.
As a Crown corporation: We are responsible for
ensuring the non-partisan provision of programs
and services by our organization.
As federal public servants: We must ensure we
serve the public interest and uphold the public
trust by taking all possible steps to prevent and
resolve any real, apparent or potential conflicts of
interest between our roles and official
responsibilities, and our private affairs
and activities.
18
How do we achieve this?
Conflict Disclosure
We achieve this by ensuring that our decision-
making is free from any real or perceived conflicts
of interest. Where we think there “may” be a real,
apparent, or potential conflict of interest we
disclose the situation to Human Resources or
CCC Legal Team.
Conflicts of interest arise but the Code requires
each employee to disclose the conflict. This will
ensure that the conflict of interest is managed as
appropriate and that decisions are made in a
manner that upholds the public trust.
Where do conflicts arise?
Conflicts can arise in any situation where your
personal interests detract from your work
responsibilities or could influence your
impartiality. However, examples of conflicts of
interest include when your decision-making or
work is influenced by:
 Your personal or financial interests;
 Your personal or social ties;
 Outside employment and activities;
 Concurrent appointments; or
 Participation in certain political activities;
Adherence to this Code and the TBS Code
minimizes the possibility of conflicts arising
between an employee’s private interests and his
or her official duties. Moreover, the Treasury
Board has a detailed policy which addresses
Conflicts of Interest entitled the Policy on
Conflict of Interest and Post-Employment.
CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019
If you have questions at any time, wish to declare
a conflict of interest or are unsure whether you
are in a conflict of interest situation, you can
contact Human Resources.
5.5 Environmental Impacts
CCC is committed to respecting the environment
and the environmental laws of the countries
where our projects will be undertaken. We also
consider the corporate environmental policies
and environmental management systems of
Canadian exporters and their partners (such as
project sponsors or lenders), where applicable. In
cases where projects are funded through export
credit agencies or international organizations
such as the World Bank, CCC adopts the
requirements set by those institutions.
For projects with potential environmental
impacts, we conduct a formal environmental
review process and comply with the Canadian
Environmental Assessment Act, 2012, under the
purview of the Canadian Environmental
Assessment Agency (CEAA). In accordance with
CEAA, CCC will only carry out a project outside
Canada if we determine it is not likely to cause
significant adverse environmental effects.
Furthermore, CCC also strives to take into
account sustainable development considerations
(economic, social and environmental) as part of
an appraisal of all the risks in our transactions.
FURTHER
READING
CCC Environmental Assessment Instruction.
19
 6. CONCLUSION

However, this Code cannot cover every

Responsible business situation. If you are unsure of what to do, you
conduct and sound must seek advice. Your manager, Human
Resources, or the CCC Legal Team can help.
ethical behaviour are This is particularly important and relevant if you
suspect that someone is violating this Code in
vital to maintaining
any way or otherwise putting CCC at risk. It is
CCC’s credibility and your duty to speak up, and you will be protected
when you do so.
reputation.
Remember, together, we can make a difference,
and be the change we want to see in the world.
Each of us is responsible for upholding not only
CCC’s and the public sector’s values but also
the high standards we have set for responsible
business conduct. Abiding by this Code
is key.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 20
 ANNEX A

Values and Ethics Code for the Public Sector

Statement of Values

These values are a compass to guide public servants in everything they do. They cannot be considered in
isolation from each other as they will often overlap. This Code and respective organizational codes of
conduct are important sources of guidance for public servants. Organizations are expected to take steps
to integrate these values into their decisions, actions, policies, processes, and systems. Similarly, public
servants can expect to be treated in accordance with these values by their organization.

Respect for Democracy

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the
public interest. Public servants recognize that elected officials are accountable to Parliament, and
ultimately to the Canadian people, and that a non-partisan public sector is essential to our
democratic system.

Respect for People

Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian
public and contributes to a safe and healthy work environment that promotes engagement, openness and
transparency. The diversity of our people and the ideas they generate are the source of our innovation.

Integrity

Integrity is the cornerstone of good governance and democracy. By upholding the highest ethical
standards, public servants conserve and enhance public confidence in the honesty, fairness and
impartiality of the federal public sector.

Stewardship

Federal public servants are entrusted to use and care for public resources responsibly, for both the short
term and long term.

Excellence

Excellence in the design and delivery of public sector policy, programs and services is beneficial to every
aspect of Canadian public life. Engagement, collaboration, effective teamwork and professional
development are all essential to a high-performing organization.

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 20
 ANNEX B

Employee Code of Conduct and Business Ethics

Acknowledgement and Acceptance Form
To be generated and accepted electronically

I have read and understood the Canadian Commercial Corporation’s “Code of Conduct and Business
Ethics” and the “Values and Ethics Code for the Public Sector” in the past thirty (30) days.

I have also reviewed the Conflict of Interest sections in detail and declare that I have no conflict, real or
perceived that I have not previously declared.

By clicking my acceptance, I agree to abide by the obligations and to respect the principles set out in
these documents.

Electronic Signature (Employee) Date

CCC Code of Conduct and Business Ethics – Board Approved April 15, 2019 21